Section 194A(3)(iii)(a) & 194A(3)(v) of the Income Tax Act, 1961 – TDS – Benefit of Exemption under section 194A(3)(iii)(a) would apply only when the interest income in respect of deposit made with the treasury accrues/arises to a Co–operative society engagee in carrying on the business of banking, which in turn involves acceptance of deposits from the public and not merely from it's own members; therefore,  in respect of the deposits made by the assessee primary agricultural Credit Societies with the treasury, they will not be entitled to the benefit of Exemption under section 194A(iii)(3)(a) – Chirayinkeezhu Service Co-operative Bank Ltd vs. CBDT[2020] 312 CTR (Kerala) 277